Grants Management Handbook Policies and Procedures for Grants and Contracts Management Last Updated: 8/28/17

Grants Management Handbook Policies and Procedures for Grants and Contracts Management Last Updated: 8/28/17

Table of Contents SUMMARY... 4 OVERVIEW OF PROJECT DIRECTOR S RESPONSIBILITIES... 4 KEY COLLEGE PERSONNEL... 5 Grant Development Staff... 5 Grant Accounting Staff... 6 Purchasing Agent... 7 Accounts Payable Staff... 7 Office of Institutional Research Staff... 7 Roles and Responsibilities Matrix... 8 GETTING STARTED... 9 Notice of Award... 9 Negotiating a Grant Award... 10 Institutional Review Board... 10 Grant Regulations... 10 Proposal and Budget... 11 Subrecipient Agreements... 13 Publicity... 14 Committees... 14 Evaluation... 15 Budget Monitoring and Activity Tracking... 15 Linking Fiscal and Programmatic Data on Federal Grants... 15 Internal Management Plan... 16 Budget with Internal Identifiers... 17 Activity Report... 17 Unit Costs... 19 Program Officer... 20 GRANT MANAGEMENT NAVIGATION MAP... 21 GRANT PERSONNEL... 21 New Hires... 21 Existing Faculty and Staff... 22 Consulting Fees, Participant Stipends, and Honoraria... 25 1 P a g e

Time and Effort Documentation... 25 Time and Effort Determination... 26 Time and Effort Options... 26 Accounting for 100% of Effort... 28 Time and Effort Record Retention... 28 Time and Effort System Annual Review... 29 When to Use a Contract for Personnel Who Are Not New Hires... 29 Annual Salary Increases... 29 Payout for Departing Employees... 29 Vacation Leave... 29 Sick Leave... 29 Personal Day(s)... 30 Benefits End... 30 GRANT COMPLIANCE... 30 Government Accountability Office (GAO) Risk Criteria... 30 Federal Awardee Performance and Integrity Information System (FAPIIS)... 31 Grant Compliance Best Practices... 32 Grant Compliance Committee... 32 GRANT EXPENDITURES... 32 Allowable Costs Policy and Procedure... 32 Definitions... 33 Procedure... 34 Monitoring Expenditures... 34 Procurement of Goods and Services... 35 Office Supplies... 36 End-of-Year Purchasing... 36 Equipment and Instructional Materials... 36 Disposition of Equipment... 37 Contracted Services and Consultants... 38 Travel... 38 Support Services... 38 Subrecipients... 38 2 P a g e

GRANT BUDGET SPECIAL CATEGORIES... 38 Indirect Costs... 38 Documentation of Local Match... 40 Valuing Time of RTC Faculty and Staff... 41 Valuing Existing Equipment and Facilities Costs... 42 Valuing Third Party In-Kind Contributions... 42 Employees of Partnering Organizations... 42 Volunteers... 42 Supplies... 43 Equipment and Facilities... 43 Leveraged Resources... 43 Program Income... 44 Transfer of Funds... 44 Carryover of Funds... 45 Single Audit... 45 PROJECT REVISIONS... 45 Need for Prior Approval... 45 Supplanting... 47 No-Cost Extension... 48 INSTITUTIONAL REVIEW BOARD (PROTECTION OF HUMAN PARTICIPANTS)... 48 RECORDS AND DATA MANAGEMENT... 49 REPORTING... 50 CLOSE-OUT... 51 Final Activities... 51 Records Retention... 52 GRANT RESOURCES... 53 GLOSSARY OF COMMON GRANT ACRONYMS... 53 3 P a g e

SUMMARY The guidelines in this handbook will assist project directors, principal investigators, and other grant-funded staff in navigating the grants and contracts management processes at Renton Technical College. The Office of Grant Development will work closely with project directors to ensure the success of the project and to answer any questions that may arise along the way. For questions or concerns about compliance, outcomes, evaluation, reporting, etc. contact: Marta Burnet Director of Grant Development mburnet@rtc.edu Room C-112, Telephone: (425) 235-2352 x2103 For questions or concerns about business office processes, purchasing, etc. contact: Mark Johnson Director of Financial Services Mark.johnson@rtc.edu Room J-114A, Telephone: (425) 235-2352 ext. 5509 OR Susie Rather Grant and Contract Coordinator srather@rtc.edu Room J-114, Telephone: (425) 235-2352 ext. 5699 OVERVIEW OF PROJECT DIRECTOR S RESPONSIBILITIES To successfully manage a funded grant, a project director must be familiar not only with funding agency policies and program regulations, but also with the grants management procedures of Renton Technical College (RTC). Having a thorough understanding of the responsibilities of the project director and other college personnel will enable the project director to complete the tasks necessary to ensure accountability for grant funds. The project director, or principal investigator, has full authority to administer a grantfunded project and the responsibility of implementing project activities with grant funds to achieve stated objectives. The responsibilities of the project director may include, but are not limited to, the following: Implement and/or coordinate all project activities and manage day-to-day operations, working closely with the appropriate college departments and supervisory personnel. Maintain progress toward meeting the project s goals and objectives. 4 P a g e

Comply with all regulations of the funding agency. Administer the grant budget according to program requirements, initiating and monitoring grant expenditures, working with Grants Accounting to reconcile discrepancies, and requesting Grants Accounting to make budget revisions or, if necessary, submitting budget modification requests to the funding agency for approval. Link financial data to programmatic data as outlined in RTC Policy Chapter 1, Section 14 Track matching and leveraged funds, including in-kind contributions, when applicable. Process and approve purchase requisitions using PSS 2. Review invoices and compare with purchase orders, obtain the required signature/approval to authorize payment, and disburse payments for invoices. Ensure proper use and accountability of grant-funded equipment and supplies. Hire, train, and supervise project staff, making sure there is administrative approval. Recruit project participants. Work with staff in the Communications and Marketing Department to market the program, when appropriate. Work with the Financial Aid Office to administer student financial assistance, when applicable. Maintain accurate and up-to-date project records. Distribute, collect, and ensure completion of time and effort reports that account for 100% of employees time. Prepare and submit invoices based on the fiscal agent s requirements to the Grants and Contracts Coordinator, when the College is a grant subrecipient. Coordinate the project advisory committee. Direct the project evaluation and incorporate evaluation recommendations into the project. Disseminate project information and results. Establish a relationship with the funding agency and communicate any anticipated changes to the project that may be necessary. Monitor subrecipient performance and grant expenditures, when applicable. Complete and submit reports to the funding agency as required. Prepare and submit internal reports as requested. Perform necessary close-out activities in collaboration with Grant Development and Grants Accounting staff. KEY COLLEGE PERSONNEL GRANT DEVELOPMENT STAFF The Director of Grant Development is primarily involved in the development and submission of grant applications and letters of inquiry. However, the Director of Grant 5 P a g e

Development also plays a key role in assisting project directors with understanding and fulfilling their responsibilities. The Director of Grant Development may provide: Assistance in the start-up of the grant by coordinating kick-off meetings with appropriate college faculty and staff. Orient the project director to grants management. Serve as a liaison between the project director and other college departments. Answer questions on the content of the grant proposal and the interpretation of funding agency and program regulations. Provide guidance in the development of personnel and consulting contracts and subaward agreements. Assist with the Institutional Review Board process, when applicable. Communicate with the funding agency to clarify program regulations, when appropriate. Provide guidance in complying with funding agency regulations. Assist with budget and/or programmatic changes. Provide technical and editorial assistance with required reports to the funding agency. Work with the project director in developing a continuation proposal, when necessary. In many instances, the Director of Grant Development should be the first point-ofcontact when project directors have questions about their grants. GRANT ACCOUNTING STAFF Grants Accounting staff in the Business Office are responsible for the accounting and financial reporting of grant funds as described below: Set up a cost center for the grant in the College s administrative computing system and enter the grant budget in the system. Draw down funds electronically from the funding agency s system, when appropriate. Deposit and record cash payments from the funding agency in coordination with the Grant and Contract Coordinator who initiates invoicing and tracks payments. Provide guidance on the appropriate college account categories to use. Transfer budgeted funds from one account to another as directed by the project director and approved by the funding agency, if approval is required. Monitor the expenditure of grant funds on a quarterly or monthly basis and contact project directors when grant funds are not being spent in a timely manner or when grant expenditures are not in compliance with grant regulations. Calculate and charge indirect costs to the grant, when appropriate. Post grant-funded in-house duplicating, word processing, and postage charges to grant cost centers as directed by the project director. Provide technical assistance to the project director on grant accounting issues. Provide training to project staff on viewing grant budgets and printing expenditure reports from FMS and/or FMS Query. 6 P a g e

Work with the project director to reconcile any accounting discrepancies that may occur. Maintain copies of time and effort reports for personnel who are funded on grants or devoting time to grant implementation for the local match. Work with the project director to document all local match, when appropriate. Assist the Vice President for Administration and Finance and the project director in developing and/or finalizing subrecipient agreements, if applicable. Enter blanket purchase requisitions in the PSS 2 System for subrecipient agreements and initiate processing of subrecipient invoices for payment, as needed. Process formal invoicing to the fiscal agent when the College is a grant subrecipient. Prepare and submit financial reports to the funding agency. Provide grant financial information to Grant Development staff when requested. Supply financial information on grants for internal and external audits. PURCHASING AGENT The Purchasing Agent in the Business Office has the following responsibilities in assisting project directors with issues related to purchases: Orient project director to the College s purchasing procedures. Arrange for training of project staff for training on PSS2, if approved for PSS2 use. Arrange for the setup of PSS2, the College s administrative computer system, on applicable computer(s) of approved project staff, for data entry and approval of online purchase requisitions. Disburse contract payments requested after reviewing for approval signatures. Purchase approved equipment for grant projects. ACCOUNTS PAYABLE STAFF Accounts Payable staff, located in the Business Office, have the following responsibilities in assisting project directors with payment of expenditures: Review Travel Expense Vouchers with approval signatures and disburse payments. Review credit card logs for approval and post credit card charges to correct cost center in FMS. OFFICE OF INSTITUTIONAL RESEARCH STAFF The Institutional Research Manager can assist project directors with data collection, analysis, and reporting, as well as the development and distribution of surveys for project evaluation. However, this assistance must happen at the start of the grant to ensure data can be collected in the correct way and with ample time before reporting deadlines. Contact Heather Knous-Westfall, at hknous-westfall@rtc.edu or (425) 235-7 P a g e

2352 ext. 2042 for more information and assistance with institutional research queries and data analysis. ROLES AND RESPONSIBILITIES MATRIX Project Activity Primary Responsibility Secondary Responsibility Authorize grant acceptance VP, Administration & Finance President Conduct initial grant Director of Grant Development Project Director (PD) management training Prepare college grant budget forms PD, then Business Office Director of Grant Development Activate and manage grant Project Director and Dean Business Office activates budget manage Recruit/hire project personnel Human Resources, Dean Project Director Supervise project personnel Project Director, Dean Director of Grant Development Purchase equipment and supplies Project Director with Purchasing Agent Director of Grant Development, as needed Develop subcontracts Project Director, Dean Director of Grant Development, as needed Implement/attain objectives Project Director and project Director of Grant and contract agreements Review/monitor monthly budget reports and spend down to $0 Maintain accurate activity files/reports, certify time/effort, student and other data Publicize and disseminate outcomes Implement evaluation plan Prepare interim and final program and fiscal reports and modifications staff Project Director and Dean Project Director (Activities, goal attainment, student records, personnel time, purchases, contracts, reports, budgets) Project Director Project Director, External Evaluator/IR Manager Project Director (prepares and submits) Development Grant & Contract Coordinator Dean, Director of Grant Development (contracts/reports); Grant & Contract Coordinator (budget and expenses) Director of Communications and Marketing Director of Grant Development Grant & Contract Coordinator and Director of Grant Development (reviews and approves) Maintain project quality control Project Director Director of Grant Development, Dean Track matching funds and inkind Project Director Business Office contributions Institutionalize project elements and/or identify program/fiscal steps Project Director/Dean/VP for Instruction Director of Grant Development and RTC Cabinet Establish relationship/cultivate funding agency Project Director Director of Grant Development 8 P a g e

Complete project on time/within budget, close out and prepare for audit Project Director Business Office, Director of Grant Development (as needed) GETTING STARTED NOTICE OF AWARD The funding agency will mail an official written notification of the grant award. All original award documents will be housed in the Business Office with the Grant and Contract Coordinator. The notification from a government agency will be in the form of a signed grant award document (Grant Award Notification or GAN for federal grants; Award Letter for State Board administered grants) and an approval letter; these may be sent to the College president and/or the project director or contact person named on the application cover sheet (often these documents are sent to the Vice President of Administration and Finance). Alternatively, the funding agency may send the grant award document directly to the Director of Grant Development if the staff member s name is listed as the contact or if the staff member has signed off as the Authorized Organizational Representative. Regardless of who receives notification, the original document should be forwarded to the Business Office (Grant and Contract Coordinator) along with a copy of the grant proposal and the grant guidelines. The project director and the Director of Grant Development should keep a copy of the proposal, guidelines and award notice as well. If a separate contract is sent to be signed and returned to the funding agency after notification by letter, the signature of the appropriate college representative, which in most cases will be the President and/or the Vice President of Administration and Finance, will be obtained and the document mailed back to the funding agency. The original fully executed contract that is returned by the funding agency should be sent to the Business Office (Grant and Contract Coordinator), with a copy kept on file by the project director and Director of Grant Development. Most government agencies use electronic wire transfers to send grant funds to recipients. Some funding sources send checks upon submission of an invoice. In all cases, the Director of Financial Services is responsible for setting up these processes. Foundations and corporations usually notify the contact person (Director of Grant Development) on the grant application by letter or e-mail. The Business Office, Grant Development Office, and the project director should all have a copy of the notification, with the Business Office (Grant and Contract Coordinator) housing the original notification document and a copy of any guidelines pertinent to the grant. Checks should be made out to the College and may be sent to the project director or Director of Grant Development. If a check is made out to the College, it should be forwarded to the Business Office (Grant and Contract Coordinator) along with the award document. If a 9 P a g e

check is made out to the Renton Technical College Foundation, it should be forwarded to the Foundation Director who will sign it over to the College. Any paperwork the funder requires will be completed and submitted by the Director of Grant Development or the Foundation Director, who will also send a thank-you letter to the foundation or corporation. The project director will review the award documentation and make note of the amount awarded, award number, starting and ending dates, fiscal years of a multiyear grant, program officer contact information, reporting requirements, and any limitations or changes from the original proposal. Any reduction in the amount awarded from the requested amount will require a budget modification unless the budget has already been revised in the negotiation stage prior to the grant award. If a project director will be hired through the grant, the primary budget authority/grant manager should review this documentation. NEGOTIATING A GRANT AWARD If a grant must be negotiated before it is funded, the project director will work with the Director of Grant Development and the Business Office to provide the funding source with answers to questions, supplemental documentation, and programmatic and budget modifications, as necessary. Budget modifications will need to be reviewed by the Business Office (Grant and Contract Coordinator and/or Director of Financial Services). If substantial budget cuts or changes to the project, college commitments, or local match are requested, a decision may need to be made at a higher level (e.g. appropriate vice president, college executives, President s Cabinet) on whether the College can accept these requirements and implement the project with the changes. If the project is not feasible as a result of the requested changes, the award may be declined. INSTITUTIONAL REVIEW BOARD If approval by the College s Institutional Review Board (IRB) involving human participant research is required and has not been obtained by the time notification of a grant has been received, approval must be obtained within four weeks. Refer to the Institutional Review Board website for guidance on approval requirements, procedures, and forms. GRANT REGULATIONS Federal grants operate under the following hierarchy of regulations (e.g. EDGAR [Education Department General Administrative Regulations] takes precedence over Office of Management and Budget [OMB] Uniform Guidance). The below list ranks regulation sources in precedence from highest to lowest: Authoring legislation created by Congress (both program-specific and general provision sections of the statute). Code of Federal Regulations (CFR) program regulations from the statute and administrative regulations created by the agency (e.g. U.S. Department of 10 P a g e

Education EDGAR, National Science Foundation Proposal and Award Policies and Procedures). Office of Management and Budget Uniform Guidance (governing all federal agencies) now supersedes the requirements of various other OMB circulars, including: o OMB Circular A-110 (2 CFR 215) Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Nonprofit Organizations. o OMB Circular A-21 (2 CFR 220) Cost Principles for Educational Institutions. o OMB Circular A-133 Audits of States, Local Governments, and Non- Profit Organizations. Grant Award Notice (GAN). Non-regulatory guidance informal advice and best practices from program officers. Letters and press releases from the federal agency. NOTE: For federal grants, federal law takes precedence over state law. Federal agencies and programs within agencies are not always consistent in interpretation or enforcement of regulations. Although earmarked or appropriations funding bypasses the competitive grant process of federal and state agencies, earmarked funds must still be spent and accounted for in conformance with applicable federal and/or state regulations. The award is usually accompanied by a grant agreement or contract specifying the amount, purpose, and time period of the funding and the administrative requirements for which the grantee must adhere, including requirements for submission of any performance or financial reports. Nonfederal grants are usually governed by the program guidelines accompanying the grant application package. The Director of Grant Development will meet with project directors before grant activities begin to review the regulations and guidelines so that project directors can be thoroughly familiar with the requirements of their grant projects. The Director of Grant Development can assist project directors when there are questions about eligible activities, allowable expenditures, and other compliance issues. PROPOSAL AND BUDGET The project director should review the grant proposal thoroughly, paying particular attention to the objectives, activities, outcomes, key personnel, timeline, partnering organizations, management plan, evaluation, and budget. Modifications may need to be made to the project design that was initially laid out in the grant proposal (refer to the Project Revisions section below). If the objectives need to be amended, the project 11 P a g e

director should request permission from the funding agency program officer as soon as possible. The Director of Grant Development will introduce new project directors to the Grants Accounting staff for review of the financial aspects of the project and the College s accounting procedures for managing the grant. A grant kick-off meeting will be held with staff from other departments to ensure everyone has knowledge of the grant and their responsibilities for implementation. These meetings may include the project director s supervisor, appropriate deans or associate deans, Director of Human Resources, Director of Financial Aid, Information Technology staff, Business Office staff and/or others depending on the nature of project activities. Note: During the kick-off meeting (when applicable), the group will be made aware of the appropriate Classification of Instructional Programs (CIP) code(s) assigned and/or linked to the project CIP codes are assigned by the Washington State Board for Community and Technical Colleges (SBCTC) to all programs that are currently approved by the state. In addition, information regarding dual enrollment options for students will be discussed at the kick-off meeting. Any questions regarding student funding eligibility and dual enrollment options should be directed to the Financial Aid Office. After a signed grant award notice or fully executed contract has been received, the Business Office (Director of Financial Services or Grant and Contract Coordinator) will set up a budget number for the grant in the FMS administrative computing system. The budget number begins with 145-XXX-XXXX (there are 10 numbers total). All departments involved in the grant will be notified when the budget number is assigned. The budget number must be used on all grant expense documents. Business Office staff (Director of Financial Services or Grant and Contract Coordinator) will enter the grant budget into the appropriate expense accounts in FMS. The billing is converted to the funding agency s particular expense designation by hand as invoices are prepared. The budget key created by the Business Office should always be followed when charging expenses to the grant; the budget key matches compatible internal accounts with the funding agency accounts. If an account on the budget key seems inappropriate for a particular expense, the project director should contact the Business Office (Grant and Contract Coordinator) to see if the budget key should be adjusted. If a project director does not already have a user ID for accessing FMS Query, the project director s supervisor must request this from the Grant and Contract Coordinator. A project assistant, and/or other project staff, may also need IDs. The Business Office will consult with the project director about which project staff will need access and will provide this information, along with the grant organization and fund numbers, to the Purchasing Agent who will set up the user profile for the appropriate individuals to have access for data entry or approval of purchase requisitions in FMS. 12 P a g e

Expenses cannot be incurred prior to the start date or after the end date, although some federal agencies may allow pre-award costs up to 90 calendar days before the start date and up to a one-year no-cost extension of the end date. (Refer to the Project Revisions section.) It is RTC s policy that no expenses may be incurred until the Business Office receives a fully-executed contract or notice of award. The Vice President for Administration and Finance may make exceptions for continuing grants and grants for which written substantial approval has been received. For federal grants and many other types of grants, expenses are incurred when an obligation has been made, according to the following guidelines: (Some funding agencies may have different regulations; e.g. requiring all expenses to be paid by the end date of the grant) Purchasing property Personal services (employer) Personal services (contractor) Other work Public utility services Travel Rental of property Upon a binding written commitment When the services are performed Upon a binding written commitment Upon a binding written commitment Upon receipt of services When the travel is taken When the property is used If the grant involves hiring personnel for new grant-funded positions, the hiring process should begin immediately (refer to the Grant Personnel section). SUBRECIPIENT AGREEMENTS If other organizations will be partners on a grant of which they will be responsible for providing certain programs or activities for the grant project and receiving a portion of the grant funds in support of their defined roles and responsibilities, a subrecipient agreement will be drafted (if not already completed as part of the grant application). Preliminary agreements will be finalized and signed by all parties. The original agreement will kept on file in the Business Office, with a second original distributed to the partner organization(s). A copy will be maintained by the project director and Director of Grant Development. A subrecipient agreement will identify the source of funding and, if the funding is federal, include the Catalog of Federal Domestic Assistance (CFDA) number and title. The agreement will address the mechanisms for monitoring fiscal and programmatic operations and include the following: Scope of work with deliverables (a copy of the proposal can be an attachment) Project period (start and end dates) Payment schedule and invoicing Budget Site visit provisions site reviews should include review of: - Policies and procedures - File documentation 13 P a g e

- Financial reporting - Payroll - Travel - Accounting system - Management and administration - Inventory Reporting requirements Provisions for access to accounting records Indemnity clause Modifications and termination Ownership of intellectual property Confidentiality References to federal and state laws (e.g. time and effort reports, matching documentation, Uniform Guidance compliance) The subrecipient agreement should not include anything that cannot be monitored. Subrecipient agreements should be drawn up in consultation with, and approved by, the College s Vice President for Administration and Finance. The project director should check the Excluded Parties List System before partnering with a subrecipient to see whether the potential subrecipient is excluded from receiving federal funds. PUBLICITY The Communications and Marketing Department will assist with publicizing a grant award and/or advertising a grant program to recruit participants. Staff in this department will work with grant project staff to prepare press releases to the local media and develop marketing materials and advertisements. For significant grant awards, they will coordinate press conferences with college leaders and partnering organizations. As the grant is being implemented, the Communications and Marketing Department should be kept informed of any noteworthy activities that should be communicated internally to the College community and/or externally to the public. For more information on publicity, contact the Director of College Relations and Marketing, Katherine Hansen, at khansen@rtc.edu or 425-235-2356. NOTE: The funding agency should be credited on any publicity materials or developed products. Be sure also to include any required equal opportunity statements. COMMITTEES If the project involves a program advisory committee, the project director, in collaboration with the appropriate Dean, should form the committee as early as possible if it has not already been formed in the grant development stage. The same is true for any type of internal steering committee or review committee (e.g. to review scholarship applications or oversee grant activities). 14 P a g e

EVALUATION If the project includes an external evaluation, the project director should contact the evaluator identified in the proposal or work with the appropriate RTC staff to immediately begin a search for a qualified evaluator if one has not already been selected. Conversations with the evaluator should be held as soon as possible, and the evaluator should be given a copy of the grant to review. Arrangements for site visits should be planned well in advance. Baseline data should be collected immediately unless the data provided in the grant proposal will serve as the baseline. The project director should work with the Institutional Research Manager to collect the necessary data throughout the grant period. BUDGET MONITORING AND ACTIVITY TRACKING The project director will regularly monitoring grant expenditures against the approved budget, reviewing charges posted in FMS, and working with the Grant and Contract Coordinator to reconcile any discrepancies between project files and FMS postings. Budgets should be monitored at least monthly or more frequently if the grant budget is large. Note: ALL grant-funded projects should be identified with an unusual action code that is assigned by the Registrar s Office identifying students who are project participants. This will assist all parties involved in tracking and reporting on the progress of students as well as the project as a whole. The project director should develop a system to track project activities to ensure they are properly implemented within the appropriate timeframe. LINKING FISCAL AND PROGRAMMATIC DATA ON FEDERAL GRANTS As presented in the related policy (RTC Policy Chapter 1, Section 14), the Uniform Guidance ( 200.301 Performance Measurement) outlines the requirements for providing financial and performance information. To comply with these regulations, Renton Technical College (RTC) will require any federally-funded projects or programs to develop and utilize a system to relate financial data to performance data using an objective and quantifiable approach that includes the development of unit cost data, when applicable. Where RTC is a sub-awardee, it will utilize the approach provided by the lead grantee. The project director, or Principal Investigator (PI), is responsible and accountable for compliance with all federal regulations associated with the grant award, including reporting on financial and performance data. 15 P a g e

The federal awarding agency is required to provide recipients with clear performance goals, indicators, and milestones at the time of the grant award. Typically, these will be based on the submitted and approved grant proposal. The agency will also provide instructions about how and when to report financial and performance information. The PI should ensure that all reporting deadlines are met and in the format requested by the funder. These procedures recommend the adaption of three existing items to blend programmatic data and financial data. First, creating an internal management plan that combines the traditional work plan with financial data. Second, adding activity codes to the internally tracked budget to be able to link expenses with specific objectives and activities. And third, developing an activity report as outlined below that will form the basis of the performance report. Internal Management Plan In order to relate financial data to performance accomplishments of the Federal award, the PI (or supervising dean if a PI is not yet in place) should review the funding award and approved proposal to: Identify project-specific activities along with their frequency; Link activities to particular deliverables or objectives; and Determine the associated resources needed for each activity (funds, staff time, and other resources). Once activities are identified/clustered, the PI should set up a timeline for activities and milestones according to reporting timeframes (e.g. quarterly or six-month milestones for semi-annual reports) and then establish an internal management plan (IMP) on the activities. This IMP should include objectives, activities, expenses and the timeline, outlining which financial expenditures are linked to which activities and outcomes. This is very similar to the idea of a work plan, but it is important to include the financial data as well. The director of grant development and the grants and contracts coordinator should be consulted to ensure alignment with compliance regulations. The supervising Dean should approve the reporting structure and plan. Please note it is up to the grant PI and supervising dean to determine what format the IMP should take. A narrative and table example are included as samples. For example, To improve student retention by 10% (i.e. objective) in year one of the grant (i.e. timeline), we will offer weekly tutoring and monthly workshops on study skills (i.e. activities) to 100 Upward Bound students. The associated resources (i.e. financial expenditures) are: tutor s salary and benefits ($1,000), local travel (mileage reimbursement, parking) to high schools to offer workshops ($200), 20 hours of the project director s time to prepare and run workshops ($1,000), printed materials for workshop ($200), and room rental ($50). See suggested table format below. 16 P a g e

Table 1: Internal Management Plan (IMP) Objective 1.2: Improve UB student retention by 10% in Year 1 Activity 1: Weekly Tutoring Expenses: Tutor salary & benefits $600 Timeline: 4 hours a week for 36 weeks (September May) Activity 2: Study Skills Workshop (8 workshops) Expenses: 20 hours of PI time to prepare and run workshops $1,000 Local travel to offer workshops $200 Printed material $200 Room rental $50 Timeline: Monthly (October May) Budget with Internal Identifiers Using the IMP, the PI should consider tagging budget line items in an excel spreadsheet (or however the PI will internally track spending) with an internal identifier to make it clear which expense is linked to which objective and which activity. See example below. This way, grant staff can sort expenses by activity and/or objectives, which can be helpful in completing federal reports. Note, it may be that line items apply to multiple objectives and or activities. Consider including an estimated division of each line item when applicable (e.g. 20% of time for tutoring, 80% for workshops). Table 2: Sample Budget with Internal Identifiers Expense Amount Objective Code Activity Code Five Student Mentors ($12/hr x 5hrs/week for 10 weeks/winter quarter) $3,000 Objective 4: % of Students Applying to College Mentoring/College Application Activity Report For each grant, then the PI will produce an activity report that blends the financial expense data with an internal progress report on activity data and may include an estimate on % complete. This report should be produced on a regular basis (at least quarterly) and should be reviewed internally by the grant staff, dean, the grants and contracts coordinator, and the director of grants. ANYONE ELSE? This activity report should have three key comparisons: 1. Internal progress report on activities/milestones to the internal financial expenditures for each activity/milestone during a particular time period; 2. Total expenditures for the activities identified in the progress reports; and 3. Results compared to the initial IMP (See Table 1). 17 P a g e

Table 3: Activity Report Objective 1.2: Improve Upward Bound student retention by 10% in Year 1 Activity 1: Weekly tutoring Expenses: Tutor salary & benefits $600 Timeline: 4 hours a week for 36 weeks (September May) Activities and period comparison: 36 hours (3 hours/week for 12 weeks) of tutoring, $100 spent winter trimester, $250 cumulatively, 10 hours less than initially planned. Overall progress: 58% (48 hours fall, 36 hours winter) This report should then: Note where performance goals were met on time or early and what the benefits were. When goals are not met, what are the reasons? What is the internal and external impact? Identify any time adjustments, cost overruns, underspending, and delays. Clarify potential changes in timeframe for meeting goals or in costs (which may require an adjustment to the award (budget and/or scope). Table 4: Activity Report Continued Activity Activity was partially met in that 100 students received tutoring support, Status: but was for an average of three hours a week rather than four. Objective Not met. Upward Bound student retention was only increased by 5%. Status: Explanation: The tutor only worked 30 hours rather than 40 hours in the quarter. He worked one hour less a week, because students were not staying for a fourth hour of support. With college applications due in fall, many students had needed that additional support, but that was not the case in winter. Adjustment: Based on student feedback, the tutoring schedule was retooled for spring quarter. To better utilize funds, the tutor will instead work for 2.5 hours, twice a week (5 hours total) in spring to accommodate more students schedules and fully utilize these funds. This additional support will help students prepare for graduation and ultimately will not impact the overall timeline of the project. Note that if the Activity status was Met then there would be no need for the explanation and adjustment boxes. Some activities may be very specific as the example above and some may be more vague (e.g. Met with four external partners to promote our program (6 hrs), and was invited to participate in two career fairs as a result). The activity report should be created in a format that will translate easily into the performance reporting required by the funder. 18 P a g e

Unit Costs Ultimately, the PI must provide the funder with cost information to demonstrate cost effective practices (e.g., through unit cost data). This will demonstrate how much is being spent on each objective and activity and what the results are. Table 5: Sample Activity Summary for Unity Costs Totals Amount Participants Hours $/Participant $/Hour Students $100,000 1,000 5,000 $100 $20 Tutoring $20,000 300 1000 $67 $20 Mentoring $10,000 100 500 $100 $20 Counseling $30,000 250 250 $120 $120 Field Trips $5,000 25 2,000 $200 $3 Workshops $15,000 175 750 $86 $20 Cultural Event $20,000 150 500 $133 $40 With the breakdown in Table 5, the PI can then calculate whether an activity has a high or low Unit Cost. In this example, the total student average is what determines whether something is low or high cost. This amount could be determined in another way as long as it is approved by the supervising dean as part of the IMP. Table 6 High v. Low Unit Cost Activity $/Participant High or Low Cost Students Total $100 (average for all Mid activities) Tutoring $67 Low Mentoring $100 Mid Counseling $120 High Field Trips $200 High Workshops $86 Low Cultural Event $133 High Then, based on the evaluation results and outcomes (e.g. survey results showing that a workshop was ineffective and/or notable improvement in tutored students GPA), how effective was each of the activities? For example, tutoring may cost $20,000 a year and help 300 students whereas counseling costs $30,000 and helps 250 students. It could be that the counseled students have a 20% higher degree completion rate than those who were just tutored, so the additional investment was worth it. This activity would fall into the high cost, high effectiveness category. It may be difficult to decipher which activity should be considered high or low in terms of effectiveness and/or which activity contributed most to the outcomes, but this initial 19 P a g e

breakdown of high versus low cost can help the PI and evaluator to determine which items seem to be less or more effective. The PI should provide evidence as to how this determination was made. For those that are high cost and less effective, the PI may want to consider moving away from that activity into more activities that are highly effective. Low cost/low effective should also be reconsidered as the budget allows. The integrated financial and performance data will be used to determine cost effectiveness of various services and/or activities and to make adjustments as needed to improve program outcomes. This analysis will happen as part of the regular grant evaluation process. A summary on the analysis and resulting changes to services and/or activities will be included in program files and in grant reports to the funding agency. In the Grant Compliance Committee, PIs will share results annually to report out about how project is progressing, what changes are being made, share lessons learned, and promote the adoption of promising practices. PROGRAM OFFICER If there are questions that cannot be answered by college staff, the project director should contact the assigned program officer at the funding agency. Program officers are willing to help and like to be informed of project progress. Establishing a relationship with the program officer is beneficial in overcoming hurdles to grant implementation, as well as in applying for additional grants. 20 P a g e

GRANT MANAGEMENT NAVIGATION MAP Grant Writer/Planning Team Contextualize; provide history and intent of the grant Marketing/Outreach Enhance online presence, print collateral, social media, industry, and CBO contacts Grant funder disclosure statement Student Services Advising support Registration Procedure/Coding Grant-specific FERPA Vet Priority of Service Policy PLA Procedure/Coding Department Meeting Review grant deliverables and responsibilities for Deans/Instructors Business Office Fiscal Reporting, invoicing, equipment/purchasing guidelines, matching requirements, allowable costs Institutional Research Review data reporting requirements and sources for obtaining data Human Resources Grant positions to be hired, job descriptions, salaries, and timelines T&E reporting EO posters/participant documentation Engagement of Other Stakeholders and Reporting Requirements CBOs, Industry Partners, Departments on Campus (i.e. WTED) - Matching, Participant Data Sharing Other Grantees as Resources Understanding who in our CTC system are recipients of similar grants and share best practices GRANT PERSONNEL NEW HIRES The established college hiring procedures should be followed when hiring new personnel for grant-funded positions. Immediately after the grant is awarded, the project director should work with the Executive Director of Human Resources, or her designee, to review the job descriptions included in the grant application or to develop job descriptions from the responsibilities of project staff listed in the grant narrative. If the project director is to be hired through the grant, the project director s supervisor and the Director of Grant Development will be responsible for working with the Executive Director of Human Resources, or her designee, to recruit candidates to fill the position. The supervisor and Director of Grant Development will also assume responsibility for any grant activities until the project director is hired. 21 P a g e

The employment of newly hired personnel on grant projects will normally end when the grant ends. Continued employment after the grant ends will be at the discretion of the College s President, who has this delegated authority from the Board of Trustees. Salaries, benefits, and annual increases must be consistent with the College s established institutional policies and collective bargaining agreements. Project staff should be paid according to the College s salary schedule, based on experience related to the duties of the grant position, which means that a starting salary may be lower than the maximum amount budgeted in the grant application. The Business Office should be notified when new employees are hired. Supervisors must be sure to use the 10-digit budget number and start and end dates included on each Personnel Action Request form. If the employee s duties will be split between two or more grants, or between a grant and a college-funded position, the correct percentage must be allocated for each position. The Executive Director of Human Resources, or her designee, uses the information on the Personnel Action Request form to charge the salaries of new employees to the appropriate grant. If the percentage or amount of salary to be charged to the grant changes during the grant period (e.g. the College picks up an increasing percentage of the salary over the life of a multi-year grant), a Personnel Action Request form must be completed and submitted to the Human Resources Department with a copy to the Business Office. This should be done at least one month before the change is to take place to allow time for the change to be implemented in PPMS and/or FMS. When completing the form, regardless of when the form is submitted, use the day that the salary change should be implemented, or should have been implemented, as the beginning date. This will serve as an indicator to the Business Office of whether or not the payroll charges to the grant started on time. If the payroll charges actually started after the beginning date indicated on the form, the Business Office will make journal entries to transfer the costs of salary and benefits as needed. The Executive Director of Human Resources, or her designee, is responsible for the hiring paperwork for full-time and part-time staff as well as issuing contracts for full-time and part-time faculty. EXISTING FACULTY AND STAFF Existing full-time faculty and staff can be compensated for their time on a grant project either through reassignment of their duties or through payment of a stipend for work over and above their normal job responsibilities (refer to Supplanting in the Project Revisions section for restrictions and guidance). The use of existing adjunct faculty or part-time staff to assume additional responsibilities as part-time staff on grants should be reviewed with the Executive Director of Human Resources to ensure that the total number of hours worked is not in violation of college policies or collective bargaining agreements regarding part-time versus full-time employment. The reassignment of 22 P a g e

existing faculty or staff should be coordinated by the appropriate Dean or Vice President, working with the Executive Director of Human Resources. When all or a portion of an existing faculty or staff member s time is reassigned to a grant project, the proportion of that person s salary and benefits representing the percentage of time devoted to the grant must be reallocated to the grant project. Reallocation is done through a Personnel Action Request (PAR) form that must be completed, signed by the hiring supervisor and Director of Financial Services, and submitted to the Human Resources Department with a copy to the Business Office (Grant and Contract Coordinator). The form must include the percentage or amount of salary that is to be charged to the grant, the payroll account number, and a start and end date for the salary allocation. If the percentage or amount of salary to be charged to the grant changes during the grant period, another Personnel Action Request form must be completed. The project director should contact the Business Office (Grant and Contract Coordinator or Director of Financial Services) for assistance in the completion of the Personnel Action form, particularly when reallocation of salaries and benefits goes into effect after personnel have already begun receiving their college-funded salary for the fiscal year. If reallocation of salaries is required, the Grant Manager, Business Office, and Dean coordinate the action needed. The Executive Director of Human Resources, or her designee, is responsible for ensuring that salaries are appropriately charged to the grant in the Personnel and Payroll Management System (PPMS) according to this form. The percentage of salary charged to the grant will be calculated on the individual s base salary. For teaching faculty, the percentage is obtained by dividing the number of credits of release time by the total credits taught for the year, excluding overloads. The following examples illustrate the proper allocation of salaries and benefits for faculty receiving release time: If a full time faculty member is released 90 hours in fall and 60 hours in spring during the 2015-2016 fiscal year, 15% of the annual salary would be charged to the grant for the period July 1, 2015 to June 30, 2016 (150 hrs divided by 990 = 15%). Example: Nine month faculty with 330 hours per quarter (330 x 3 =990 per academic year) with 30 hours release for fall and spring quarter would be 60 total hours of release or a release time percentage of 6.06% (60/990). The National Science Foundation (NSF) normally limits salary compensation for senior project personnel to no more than two months of their regular salary in any one year (i.e. payment for work done in two summer months). Salary is to be paid at a monthly rate not in excess of the base salary divided by the number of months in the period for which the base salary is paid. Compensation in excess of this amount may be approved by NSF, particularly for community college faculty teaching full loads, if sufficient justification is provided. 23 P a g e